August 30, 2004
I urge the SEC to withdraw rule s72599. I believe the rule
harms consumers by creating two different standards of conduct for persons offering financial planning services: a higher fiduciary standard for registered investment advisers and a lower one under NASD suitability rules.
The rule exempts, in effect, brokers from being required to disclose conflicts of interest when they offer financial planning services.
Allowing brokers to imply that they have a fiduciary relationship with a client, when in fact they do not, allows the type of behaviour that has caused so many scandals in our profession and it undermines public confidence in all financial